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Talariax Pte Ltd External Data Protection Notice (the “Notice”)
Updated as at 14 Sept 2023
1. Personal Data
Examples of such Personal Data you may provide to us include (depending on the nature of your interaction with us) your name, NRIC, passport or other identification number, telephone number(s), mailing address, email address, transactional data and any other information relating to any individuals which you have provided us in any forms you may have submitted to us, or via other forms of interaction with you.
2. Collection of Personal Data
2.1 Generally, we collect Personal Data in the following ways:
(a) when you submit any forms, including but not limited to application forms, and proposals;
(b) when you enter into any agreement or provide other documentation or information in respect of your interactions and transactions with us, or when you use our services;
(c) when you interact with our staff, including customer service officers, relationship managers and other representatives, for example, via telephone calls, letters, fax, face-to-face meetings and email;
(d) when your images are captured by us via CCTV cameras while you are within our premises, or via photographs or videos taken by us or our representatives when you attend events hosted by us;
(e) when you use our services provided through online and other technology platforms, such as websites and apps, including when you establish any online products with us;
(f) when you request that we contact you, be included in an email or other mailing list; or when you respond to our request for additional Personal Data, our promotions and other initiatives;
(g) when you are contacted by, and respond to, our marketing representatives and agents and other service providers;
(h) when you submit an employment application or when you provide documents or information including your resume and/or curriculum vitae in connection with any appointment as an officer, director, representative or any other position;
(i) when you use our electronic services, or interact with us via our websites or use services on our websites;
(j) when we seek information about you and receive your Personal Data in connection with your relationship with us, including for sendQuick and other range of products, or job applications, for example, from business partners, public agencies, your ex-employer and the relevant authorities; and/or
(k) when you submit your Personal Data to us for any other reason.
2.2 When you browse our website, you generally do so anonymously but please see the section below on cookies. We do not, at our website, automatically collect Personal Data, including your email address unless you provide such information or log in with your account credentials.
2.3 If you provide us with any Personal Data relating to a third party (e.g. information on your customers, spouse, children, parents, and/or employees), by submitting such information to us, you represent to us that you have obtained the consent of such third party to you providing us with their Personal Data for the respective purposes.
2.4 You should ensure that all Personal Data submitted to us is complete, accurate, true and correct. Failure on your part to do so may result in our inability to provide you with products and services you have requested.
3. Purposes for the Collection, Use and Disclosure of Your Personal Data
3.1 Generally, TX collects, uses and discloses your Personal Data for the following purposes:
(a) responding to, processing and handling your complaints, queries, requests, feedback and suggestions;
(b) verifying your identity;
(c) managing the administrative and business operations of the Companies and complying with internal policies and procedures;
(d) To perform or carry out TX’s obligations arising from any contracts entered into between you and us;
(e) to enable TX’s subcontractors, third-party agents and service providers, to fulfil obligations/services as stipulated in your contract with TX;
(f) to handle products and services requests and enquiries (including payments for products and services);
(g) facilitating business asset transactions (which may extend to any mergers, acquisitions or asset sales) involving any of the Companies;
(h) matching any Personal Data held which relates to you for any of the purposes listed herein;
(i) requesting feedback or participation in surveys, as well as conducting market research and/or analysis for statistical, profiling or other purposes for us to design our products, understand customer behaviour, preferences and market trends, and to review, develop and improve the quality of our products and services;
(j) managing the safety and security of our premises and services (including but not limited to carrying out CCTV surveillance and conducting security clearances, especially in contact tracing and emergency situations);
(k) project management;
(l) providing media announcements and responses;
(m) organising promotional events;
(n) in connection with any claims, actions or proceedings (including but not limited to drafting and reviewing documents, transaction documentation, obtaining legal advice, and facilitating dispute resolution), and/or protecting and enforcing our contractual and legal rights and obligations;
(o) managing and preparing reports on incidents and accidents;
(p) any other purpose relating to any of the above.
3.2 In addition, TX collects, uses and discloses your Personal Data for the following purposes depending on the nature of our relationship:
(a) If you are a prospective customer:
(i) evaluating your sendQuick needs and providing recommendations to you as to the type of products and services suited to your needs;
(ii) assessing and processing any purchase orders or requests made by you for products and services offered by TX; and/or
(iii) any other purpose relating to any of the above.
(b) If you are a sendQuick end user, partner, reseller or distributor, or an appointed representative (including but not limited to a mandate holder or a power of attorney):
(i) ensuring the ongoing credit worthiness of customers;
(ii) providing offers and promotions in relation to co-branded products and services;
(iii) customer outreach and relationship management;
(iv) meeting or complying with any applicable rules, laws, regulations, codes of practice or guidelines issued by any legal or regulatory bodies which are binding on TX (including but not limited to disclosures to regulatory bodies, conducting audit checks, or customer due diligence);
(v) any other purpose relating to any of the above.
(c) If you a corporate or business relationship with TX:
(i) buying or upgrading of products or providing solutions relating to sendQuick, sqoope, and other solutions that it may introduce from time to time;
(ii) networking to maintain customer relationship;
(iii) providing client servicing (including but not limited to providing customer satisfaction, proxy voting and merchant servicing) and product warranty services;
(iv) facilitating and carrying out due diligence checks;
(v) complying with any applicable rules, laws and regulations, codes of practice or guidelines or to assist in law enforcement and investigations by relevant authorities (including but not limited to disclosures to regulatory bodies, conducting audit checks, surveillance and investigation, or customer due diligence);
(vi) processing commission remuneration for sales representatives;
(vii) providing credit term and facilities (including but not limited to the evaluation of credit risks and enforcement of repayment obligations);
(viii) any other purpose relating to any of the above.
(d) If you are an agent of a referrer or other intermediary:
(i) marketing and leads management;
(ii) processing commission remuneration; and/or
(iii) any other purpose relating to any of the above.
(e) If you are a current or prospective Data Intermediary outsourced or prospected by TX:
(i) managing project tenders or the supply of goods and services;
(ii) processing and payment of vendor invoices;
(iii) complying with any applicable rules, laws and regulations, codes of practice or guidelines or to assist in law enforcement and investigations by relevant authorities (which includes disclosure to regulatory bodies or audit checks); and/or
(iv) any other purpose relating to any of the above.
(f) If you submit an application to us as a candidate for an employment or representative position:
(i) conducting interviews;
(ii) processing your application which includes pre-recruitment checks involving your qualifications and facilitating interviews;
(iii) providing or obtaining employee references and for background screening;
(iv) assessing your suitability for the position applied for;
(v) processing staff referrals; and/or
(vi) any other purposes relating to any of the above.
3.3 In addition, where permitted under the Act, TX may also collect, use and disclose your Personal Data for the following purposes (which we may describe in our documents and agreements as “Additional Purposes” for the handling of Personal Data):
(a) providing or marketing services, products and benefits to you, including promotions, loyalty and reward programmes;
(b) matching Personal Data with other data collected for other purposes and from other sources (including third parties) in connection with the provision or offering of products and services, whether by TX or other third parties;
(c) administering contests and competitions, and personalising your experience at TX’s touchpoints;
(d) sending you details of products, services, special offers and rewards, either to our customers generally, or which we have identified may be of interest to you; and/or
(e) conducting market research, understanding and analysing customer behaviour, location, preferences and demographics for us to offer you products and services as well as special offers and marketing programmes which may be relevant to your preferences and profile.
3.4 If you have provided your Singapore telephone number(s) and have indicated that you consent to receiving marketing or promotional information via your Singapore telephone number(s), then from time to time, TX may contact you using such Singapore telephone number(s) (including via voice calls, text, fax or other means) with information about our products and services (including discounts and special offers).
3.5 In relation to particular products or services or in your interactions with us, we may also have specifically notified you of other purposes for which we collect, use or disclose your Personal Data. If so, we will collect, use and disclose your Personal Data for these additional purposes as well, unless we have specifically notified you otherwise.
4. Disclosure of Personal Data
4.1 TX will take reasonable steps to protect your Personal Data against unauthorised disclosure. Subject to the provisions of any applicable law, your Personal Data may be provided, for the purposes listed above (where applicable), to the following entities or parties, whether they are located overseas or in Singapore:
(a) TX’s related corporations as defined in the Company’s Act;
(b) companies providing services relating to insurance to TX and its employees;
(c) subcontractor’s agents, contractors or third party service providers who provide operational services to TX, such as courier services, telecommunications, information technology, payment, payroll, processing, training, market research, storage, archival, customer support investigation services or other services to TX;
(d) vendors or other third party service providers in connection with promotions and services offered by TX;
(e) any business partner, investor, assignee or transferee (actual or prospective) to facilitate business asset transactions (which may extend to any merger, acquisition or any debt or asset sale) involving any of the Companies;
(f) third party referrers;
(g) our co-brand and other business partners;
(h) our professional advisers such as our auditors and lawyers;
(i) relevant government regulators, government ministries, statutory boards or authorities and/or law enforcement agencies, whether local or overseas, to comply with any directions, laws, rules, guidelines, regulations or schemes issued or administered by any of them;
(j) hotels, travel agents and foreign embassies in relation to overseas travel arrangements for staff;
(k) external business and charity partners in relation to corporate promotional events;
(l) commercial shops and retailers in relation to providing staff welfare benefits;
(m) will only store hard copy in a locked cabinet accessible to authorized users only. Similar treatment for database records for privileged users only.
(n) any other party to whom you authorise us to disclose your Personal Data to.
5.1 When you interact with us on our websites, we automatically receive and record information on our server logs from your browser. We may employ cookies in order for our server to recognise a return visitor as a unique user including, without limitation, monitoring information relating to how a visitor arrives at the website, what kind of browser a visitor is on, what operating system a visitor is using, a visitor’s IP address, and a visitor’s click stream information and time stamp (for example, which pages they have viewed, the time the pages were accessed, and the time spent per web page).
5.2 Cookies are small text files stored in your computing or other electronic devices which allow us to remember you or other data about you. The cookies placed by our server are readable only by us, and cookies cannot access, read or modify any other data on an electronic device. All web-browsers offer the option to refuse any cookie, and if you refuse our cookie then we do not gather any information on that visitor.
5.3 Should you wish to disable the cookies associated with these technologies, you may do so by changing the setting on your browser. However, you may not be able to enter certain part(s) of our website.
6. Data Security/Protection
6.1 TX will take reasonable efforts to protect Personal Data in our possession or our control by making reasonable security arrangements to prevent unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks. However, we cannot completely guarantee the security of any Personal Data we may have collected from or about you, or that for example no harmful code will enter our website (for example viruses, bugs, trojan horses, spyware or adware). You should be aware of the risks associated with using websites.
6.2 While we strive to protect your Personal Data, we cannot ensure the security of the information you transmit to us via the Internet or when you use our electronic sendQuick services, and we urge you to take every precaution to protect your Personal Data when you use such platforms. We recommend that you change your passwords often, use a combination of letters and numbers, and ensure that you use a secure browser.
6.3 If applicable, you undertake to keep your username and password secure and confidential and shall not disclose or permit it to be disclosed to any unauthorised person and to inform us as soon as reasonably practicable if you know or suspect that someone else knows your username and password or believe the confidentiality of your username and password has been lost, stolen or compromised in any way or that actual or possible unauthorised transactions have taken place. We are not liable for any damages resulting from any security breaches, on unauthorised and/or fraudulent use of your username and password.
7. Third-Party Sites
8. Personal Data Transfer, Return and Disposal
8.1 The personal data collected can be tranferred or return by following the data access permission and procedure as defined in the Personal Data Protection Policy of the Company
8.2 The company will dispose the personal data upon customers termination of service and contract in accordance to the data disposal policy. The customer can request for personal data disposal following the standard data access policy of the company.
9. Data Residency
9.1 The data will be residing in Singapore for Singapore customers. For other customers from other countries, the data will be residing at their local countries or otherwise stated.
10. Contacting Us – Feedback, Withdrawal of Consent, Access and Correction of your Personal Data
10.1 If you:
(c) would like to obtain access and make corrections to your Personal Data records, you can approach us via the following channels:
Email us at email@example.com
10.2 You may also write to our Data Protection Officer as follows:
Data Protection Officer
TalariaX Pte Ltd
76 Playfair Road
#08-01, LHK 2
10.3 If you withdraw your consent to any or all use of your Personal Data, depending on the nature of your request, TX may not be in a position to continue to provide its products or services to you or administer any contractual relationship already in place. This may also result in the termination of any agreements you have with TX, and your being in breach of your contractual obligations or undertakings. TX’s legal rights and remedies in such event are expressly reserved.
10.4 TX reserves the right to change this Policy with or without notice from time to time.
11. Governing Law